In yet another decision that was possibly very frustrating for the injured party involved, the claimant was denied worker’s compensation benefits after suffering a fall in the doorway of the classroom at the school where she worked. See Teacher fails to score benefits for wipeout while exiting classroom. Illinois Workers’ Compensation Law Bulletin, Volume 27, Issue 18, December 20, 2019, pp. 3-4.[1] The case discussed in the article, Geyler v. Harlem School District, 27 ILWCLB 191 (Ill. W.C. Comm. 2019), involved a claimant that was a substitute teacher who, after finishing work for the day, was leaving the classroom that she was assigned to, and was going to the front office to drop off paperwork related to the day’s teaching. The claimant was carrying work-related papers and her personal belongings (ie. her purse, water bottle, etc.), when, as she was leaving the classroom, her foot became stuck or caught on the floor of the doorway of the classroom, and as a result, the claimant fell.[2] In denying benefits to the claimant, the arbitrator took note of the fact that the claimant herself admitted at trial that she could not recall anything specifically that caused her to fall. Indeed, there apparently was no debris on the floor of the classroom doorway, nor was there any slippery or sticky substance, or materials on the floor.[3] For the most part, there also were not any students or other people in the immediate vicinity of the aforesaid classroom, and none of the papers or personal items that the claimant was carrying caused her to fall, either. It appears that the claimant just fell, when the rubber soles from one of her shoes became caught on the floor.[4] Since the fall was deemed to merely be due to an inadvertent personal misstep on the claimant’s part, it was determined to not have arisen out of the claimant’s employment. After reviewing the case, the Commission affirmed and adopted the decision of the arbitrator.[5]
The standard in this case for deciding whether an accident is connected to a claimant’s employment seems to be the same one seen in similar cases: if the associated risk or cause of the accident was not greater than that faced by the general public, then the accident was not caused by, or did not arise out of, a claimant’s employment. Yet, the claimant in the above-mentioned case was still on the job, so-to-speak, when she fell in the aforesaid doorway. She was heading to the office to drop stuff off, so even though neither the arbitrator nor the Commission could identify a specific cause of the claimant’s fall, something caused one of her rubber-soled shoes to get caught on the floor of the classroom doorway. The article is silent on these details, but it could possibly have been that the doorway floor may have been old, rough and without its original smooth finish. Of course, this is all speculation, but if it were the case that the floor itself was defective, would not this have transformed the accident into something that arose out of the claimant’s employment? Could not this have all just been presumed from the onset? It certainly could have made things much easier and better for the claima
[1]See Teacher fails to score benefits for wipeout while exiting classroom. Illinois Worker’s Compensation Law Bulletin (also cited as ILWCLB), Volume 27, Issue 18, December 20, 2019, pp. 3-4.
[1]See Id at 4.
[1]See Id.
[1]See Id.
[1]See Id.
-Attorney Matthew Ludwinski